ML20138N253

Insp Repts 50-348/85-37 & 50-364/85-37 on 850924-26,1108 & 22.Violation Noted:Failure to Have Capability to Notify State & Local Govt Agencies within 15 Minutes After Declaring Emergency

ML20138N253
Person / Time
Site:	Farley
Issue date:	11/27/1985
From:	Decker T, Sartor W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138N242	List: ML20138N237 ML20138N253
References
RTR-NUREG-0654, RTR-NUREG-654 50-348-85-37, 50-364-85-37, NUDOCS 8512230422
Download: ML20138N253 (10)

See also: IR 05000348/1985037

Text

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># #82 UNITED STATES

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_ . 'o NUCLEAR REGULATCRY COMMISSION

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$. 101 MARIETTA STREET, N.W.-

• e ATLANTA, GEORGI A 30323

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DEC i 01985 .

Report Nos.: 50-348/85-37 and 50-364/85-37

. Licensee: Alabama Power Company

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-600 North 18th Street

. _ Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-8 and NPF-2

Facility Name: Farley 1 and 2

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Inspection Conducted: September 24-26, November 8, and November 22, 1985

Inspector: TA ///37/#f

W. M. Sartor, Jr. // Date Sfgned

. Accompanying Personnel: K. Clark, G. Arthur, G. Weale, J. MacLellan, and

A.L. Smith-

Approved'by: zL, // 77 83~

T.'R. Decker Section Chief Da'te S'igned

Division of Radiation Safety and Safeguards

SUMMARY

Scope _: This . routine, unannounced inspection entailed 118 inspector-hours in the

area of a small scale emergency' exercise.

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Results: One violation was identified in that the licensee failed to have the

capability to notify responsible State and local governmental agencies within

-15 minutes after declaring an emergency.

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REPORT DETAILS

.1. -Persons' Contacted

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Licensee Employees

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• O.~W.lMorey, Assistant Plant Manager - Operations

• J. W. Beckham, Director, Farley Nuclear. Plant Visitors Center

• J.lF. Holloway, Shift Supervisor

'*R. B. Wiggines, Supervisor Operation Training Section

• N. M..Maddox, Senior Plant Instructor

• R. P.' Mcdonald, Senior Vice President

• K. W. McCracken, Manager,' Nuclear Technical Support

• C.: L. Buck, Supervisor - Nuclear Engineering

• J. E.. Garlington,. Manager- Nuclear Engineering and Licensing

• J.'W. McGowan, Manager Safety Audit and Engineering

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• W. G. Ware, Supervisor SAER Review

• T. W. Cherry, Instrumentation and Control Supervisor

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• B. L. Moore, Unit Supervisor

• B. P. Patton, Plant Health' Physicist

• R. D. Hill, Operations Manager

-*F. N. Wade, Manager Public Communications

• L.JJ. Maier, Senior Plant Instructor -

• D.- E. Grissette, Environmental Section Supervisor

• J. B. Kelly, Environmental Technician

• F. M.'Jessup, Senior Engineer

• M. A.:Treadwell- Specialist

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• J. R. Robinson, Health Physics Technician

J. F. Bouillon, Dosimetry Foreman

• W. T. Cooley, Training Coordinator

• P. E; Farnsworth, Health Physics Section Supervisor

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• D M. Varner, Manager Nuclear Administration

• T. R. Hawkins, Senior Engineer

• L. T. -Jackson, Training Sector Supervisor

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0ther licensee- employees contacted- included engineers, technicians,

operators, mechanics, security force members, and office personnel.

NRC Resident Inspectors

• W. H. Bradford

• B. Bonser

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on September' 26,1985,

with those persons indicated in paragraph 1 above. The inspector described

the areas inspected and discussed the inspection findings listed below.

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Licensee representatives stated that they did not concur with the 15-minute

notification- requirement.-and referenced the outstanding unresolved item

' addressing same -(50-348/84-26-01, 50-364/84-26-01). On November 8, 1985,

the- issue was further ' discussed via' a conference- call between

- representatives . from Region II and Farley Nuclear -Plae Following the

' discussion, Region II management personnel reviewed the issues' with NRC

Headquarters inspection and enforcement management. On November 22,.1985,

D. M. Verre111, Chief Reactor Projects Branch I at Region II notified

J. D. Noodard, Farley Nuclear Plant Manager, that a Notice-of Violation was

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-being issued. The licensee- did not identify as proprietary any of the

materials provided to or reviewed by the inspector during this inspection.

3 .' Licensee Action on Previous Enforcement Matters (92700).

.This subject was not addressed in the inspection.

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Exercise Scenario (82301)

The scenario for the emergency exercise was reviewed to determine that

provisions had been made to test the integrated capability and a major

portion of the basic elements existing within the licensee, state and local

emergency plans and organization as required by 10 CFR 50.47(b)(14),

10 CFR 50, Appendix -E, paragraph IV.F and specific criteria in NUREG 0654,

Section II.N.

The scenario was reviewed in advance of the scheduled exercise date and was-

discussed with licensee representatives both by telephone and in letters

dated August 8 and September 6,1985. As a result of the sce.nario review

the licensee augmented the scenario with contingency messages'to' ensure that

- the Emergency Operations Facility (EOF) staff's dose assessment capability

and engineering support capability could be adequately exercised. Addi-

tionally, the EOF dose assessment staff was pre positioned in Dothan such

that they could arrive at the site and demonstrate dose rate projection and

plume tracking capability independent of the Technical Support Center (TSC)

staff during the period of the effluent release.

No violations or deviations were identified.

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5. Assignment of Responsibility (82301)

This area was observed to determine that primary responsibilities for

emergency response by the licensee were specifically established and that

adequate staff was available to respond to an emergency as required by

10 CFR 50.47(b)(1),10 CFR 50, Appendix E, paragraph IV.A, and specific

criteria in NUREG 0654,Section II.A.

.The inspectors observed that specific emergency assignments had been made

for-the licensee's emergency response organization. Adequate staff was

available to respond to the simulated emergency. The initial response

organization was augmented by designated licensee representatives and

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planning for - long term or. continuous staffing .of the emergency response

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. organization _was demonstrated.

No violations or: deviations were identified.

6. -Onsite' Emergency Organization (82301)

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= iThs licensee's onsite emergency organization was observed to determine that

'the' responsibilities for emergency response were unambiguously defined, that-

adequate. staffing _ was provided to insure initial facility accident response

in' key functional areas at all times, and that the interfaces were specified -

. as required by - 10 CFR 50.47(b)(2),10 CFR 50, Appendix E, paragraph IV. A,

andLspecific' criteria in NUREG 0654,Section II.B.

The inspectors determined that the licensee's onsite emergency organization

was effective in dealing with'the simulated emergency. Adequate staffing of

Lthe emergency response facilities was provided for the initial accident

response and~the interfaces between the onsite organization and the limited

participating offsite support agencies appeared to be adequate. ~Although

the responsibilities for emergency response appeared to be unambiguously

defined, it was not apparent when responsibilities were transferred to the

Emergency Director from the shift supervisor. When the EOF was staffed, it "

was again not : apparent as to when responsibilities and which

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responsibilities were transferred from the Emergency Director in the TSC to-

the Emergency Coordinator in the EOF.

No violations or deviations were identified.

J7. Emergency. Response Support and Resources (82301)

.This. area was observed to determine that arrangements for requesting;and

- effectively using assistance resources had been made, that arrangements to

accommodate State and - local staff at the licensee's near-site Emergency

Operations Facility had been made, and that other organizations capable of-

augmenting the planned response had been identified as required by

l'0 CFR 50.47(b)(3),10 CFR 50, Appendix E, paragraph IV. A, and specific

criteria in NUREG 0654,Section II.C.

State - and local staff could have been accommodated at the near-site

Emergency Operations Facility. Licensee contact with offsite organizations

was limited in this small scale exercise. a

'No violations or' deviations were identified.

8. Emergency Classification System (82301)

This area was observed to determine that a standard emergency classification

and action level scheme was in use by the nuclear facility licensee as

required by 10 CFR 50.47(b)(4),10 CFR 50, Appendix E, paragraph IV.C, and

specific criteria in NUREG 0654,Section II.D.

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An inspector observed that the emergency classification system was in effect

as stated in the Radiological Emergency Plan and in the Implementing Proce-

'dures. The system appeared to be adequate for the classification of the

simulated accident.

No violations or deviations were identified.

9. Notification Methods _and Procedures (82301)

This area was observed to determine that procedures had been established for

notification by the licensee of State -and local response organizations and

emergency personnel, and that the content of initial and followup messages

to response organizations had been established; and means to provide early

notification to the populace within the plume exposure pathway had been

established as required by 10 CFR 50.47(b)(5)', 10 CFR 50, Appendix E,

paragraph IV.0, and specific criteria in NUREG 0654,Section II.E.

An inspector reviewed the notification methods and procedures established by

the licensee to provide information to Federal, State and the licensee's

augmented emergency response organization. During the exercise, the

inspector observed that the initial notification of an emergency

classification to the Alabama Bureau of Radiological Health and the Georgia

Emergency Management Agency was not completed until approximately 25 minutes

after the emergency declaration. This notification failed to meet the

standard of 10 CFR 50, Appendix E, Section IV.D.3 which specifies that the

licensee have the capability to notify responsible State and local

governmental agencies within 15 minutes after declaring an e,mergency. This

failure to make the notifications within 15 minutes to the States of Alabama

and Georgia was also observed in the 1984 Farley Emergency Exercise

-(reference Inspection Report Nos. 50-348/84-30 and 50-364/84-30). There was

an unresolved item addressing prompt notification from a previous inspection

report (50-348/84-26, 50-364/84-26) which was based on the finding that the

licensee did not have procedures requiring notification of offsite

authorities within 15 minutes of declaring the emergency, except for a

General Emergency, and likewise did not train the staff to make such

notifications except for General Emergencies. The licensee stated that

their understanding of 10 CFR 50, Appendix E was that the capability to

notify State and local governmental agencies within 15 minutes was fulfilled

by the existence of the communication equipment. The issue was left

unresolved pending further review by NRC. The unresolved item has now been

determined to be a violation in that:

1. The licensee's Emergency Plan does not specify that the Emergency

Director, in the event of an emergency, is to make required

notifications within 15 minutes to the States of Alabama and

Georgia.

2. Licensee's notification procedure FNP-0-EIP-26, Offsite

Notification, does not specify the 15-minute time requirement for

notifying responsible State and local response organizations

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b following ' declaration ~ of . Unusual Event, Alert and Site ' Area

b Emergency classifications.

L 3. -- straining records, interviews with training . program personnel and .

selected emergency organization personne) revealed that the

licensee's: ~ training program did not address notification time

constraints to offsite response organizations.

These . findings are' identified as ~ a violation of 10 CFR 50.54(q) which

requires licensees -_to follow. and maintain in effect emergency plans. which

meet _the standards of_10 CFR 50.47(b) and 10 CFR, Appendix E.

110 CFR 50.47(b)(5)- requires that ' the licensee's emergency plan includes

' provisions for notification of State and local response organizations; and

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10 CFR 50, Appendix E, Section IV.D.3 specifies that the licensee have the

capability to ~ notify _ responsible State and local governmental agencies

within 15 .-minutes after declaration of an emergency

(50-348/85-37-01,50-364/85-37-01).

An inspector observed the content of initial and followup notifications

and/or messages provided to offsite authorities, and noted the initial

. notification of the Site Area Emergency to the States of Alat.;ma and Georgia

-was not made _ in accordance with the Farley Emergency Plan. Specifically,

Section VI.A of the plan requires the initial message to contain as a

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minimum:

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1. Class of Emergency

2. Actual-or potential release information

3. cPotentially affected population

'4. -Advisability of protective measures

Contrary to.this requirement, the communicator providing the initial notifi-

cation gave _ only - the class of emergency although more information was

available from the . Emergency Di recto'r. This ' failure to make offsite

notification :in accordance with the Emergency Plan is identified as an

exercise weakness and will be reviewed during subsequent inspections.

~(50-348/85-37-02,364/85-37-02).

One violation was identified.

10. Emergency Communications (82301)

This area was observed to determine that provisions existed for prompt

communications among principal response organization and emergency personnel

' as required by 10 CFR 50.47(b)(6),10 CFR 50, Appendix E, paragraph IV.E,

and specific. criteria in NUREG 0654,Section II.F.

Communications among the licensee's emergency response facilities and

between the licensee's emergency response organization and offsite

authorities were adequate with one noted exception. Specifically, the

Recovery Manager was not informed of the Emergency Director's

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reclassification of the. Site Area tmergency to an Alert until 16 minutes

af ter1 the reclassification had been announced over the Emergency News

Network (ENN). 'This exercise weakness was identified by the licensee as a'

'need to make provisions to ensure that the Recovery Manager is notified of

all_ significant- ENN announcements including those originating from the TSC.

- Licensee corrective action on this exercise weakness will be reviewed during

-subsequent inspections (50-348, 364/85-37-03).

No violations or deviations were identified.

.11. Public Education and Information (82301)

This area was observed ;to determine that information concerning the

simulated emergency was made available for dissemination to the public as

required by 10 CFR 50.47(b)(7),10 CFR 50, Appendix E, paragraph IV.D, and

specific criteria in NUREG 0654,Section II.G.

Information was provided -to the media and the public in advance of the

exercise. The licensee established a near-site Emergency News Center (ENC)

and provided accurate and timely news information that was properly

coordinated. It appeared that the primary telephone response point for tne

news media would be'better located at the near-site ENC rather than from the

company's. Birmingham headquarters. A rumor control program was in place and

extensively exercised by the licensee.

No violations or deviations were identified.

12. Emergency' Facilities and Equipment (82301)

This area was observed to determine that adequate emergency facilities and

equipment to support an emergency response were provided and maintained as

i required by 10 CFR 50.47(b)(8),10 CFR 50, Appendix E, paragraph IV.E, .and

specific criteria in NUREG 0654,Section II.H.

The; inspectors observed this activation, staffing and operation of the

emergency response facilities and evaluated equipment provided for emergency

use during the exercise.

a. Control Room - An inspector observed that control room personnel acted

promptly to initiate emergency response to the simulated emergency.

Emergency procedures were readily available and the response was prompt

and effective.

b. Technical Support Center (TSC) - The TSC was activated and staffed

promptly upon notification by the Emergency Director of the simulated

emergency conditions. The TSC staff appeared to be knowledgeable

concerning their emergency responsibilities, however status boards were

either not maintained or inadequately maintained to provide timely and

accurate information. The Emergency Director did not routinely brief

the TSC personnel nor were site personnel kept informed of significant

plant events.

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c. Operations Support Center _(OSC) - The OSC was staffed promptly upon

activation by the Emergency Director. An inspector observed that. teams

.were formed promptly, briefed and dispatched efficiently. No status

boards were~ available for OSC personnel information. A Post Accident

-Sampling' System (PASS) sample was obtained under normal operating level

conditions.

d. Emergency Operations Facility - The EOF was located in the Training

Building at the reactor site. The facility appeared to be adequately

designed, equipped and staffed to support an . emergency response. The

EOF staff arrived onsite at 1116 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.24638e-4 months <br /> and assumed the responsibilities

of the radiological monitoring teams at 1232-hours.

.m. No violations or deviations were identified.

13 '. . Accident Assessment (82301)

This area was observed to determine that adequate methods, systems and

equipment for assessing and monitoring actual or potential offsite

consequences of a radiological emergency condition were in use as required

by 10 CFR 50.47(b)(9),10 CFR 50, Appendix E, paragraph IV.B, and specific

criteria,in NUREG 0654,Section II I.

The accident assessment program included both an engineering assessment of

plant status and an assessment of radiological hazards to onsite and offsite

personnel resulting from the accident. 'During the exercise, the engineering

accident -assessment team ' functioned effectively in analyzing the plant

status so as to make recommendations to the Emergency Director concerning

mitigating actions 'to reduce damage to plant equipment, to prevent release

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of radioactive materials and to terminate the emergency condition.

~ Radiological assessment activities involved several groups. A group in the

TSC effectively estimated the radiological impact in the plant based on

inplant monitoring and onsite measurements. Radiological effluent data was

received in the'TSC. Because the EOF staff activated after the effluent

release, the EOF dose assessment personnel were pre positioned and indepen-

dently' demonstrated dose rate projection and plume tracking capability. An

inspector noted that plant personnel provided a cadre for the corporate dose

assessment personnel and that the basis of this was not included in the

emergency implementing procedures. This exercise weakness was also noted by

. the licensee and the incort oration of the Safety Audit and Engineering

personnel to provide EOF dose assessment support into appropriate imple-

menting procedures will be reviewed during a subsequent exercise.

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.(50-348/85-37-04,364/85-37-04).

No violations or deviations were identified.

14. Protective Responses (82301)

This ' area was observed to determine that guidelines for protective actions

during the emergency, consistent with Federal Guidance, were developed and

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in place, and protective actions for emergency workers, including evacuation

of nonessential personnel, were implemented promptly as required by

10 CFR 50.47(b)(10), and specific criteria in NUREG 0654,Section II.J.

The simulated accident did not necessitate protective action recommendations

for - of fsite . populations. However, it was noted that no protective actions

were taken onsite during and following plume passage. The licensee also

identified E this exercise weakness and recommended reviewing training and

procedures to ensure adequate consideration is given during emergencies to

contamination control and employee radiological protection necessary due to

_ plume passage or deposition outside the Radiation Control Area. Licensee

corrective action will be reviewed in a subsequent inspection.

(50-348/85-37-05,364/85-37-05)

No violations or deviations were identified.

15. Radiological Exposure Control (82301)

This area was observed to determine that means for controlling radiological

exposures, in an emergency, were established and implemented for emergency

workers and that they included exposure guidelines consistent with EPA

recommendations as required by 10 CFR 50.47(b)(11), and specific criteria in

NUREG 0654,Section II.K.

An inspector noted that radiological exposures were controlled throughout

the exercise by issuing emergency workers supplemental dosimeters and by

periodic surveys in the emergency response facilities. Exposure guidelines

were in place for various categories of emergency actions and adequate

protective clothing and respiratory protection were available and used as

appropriate. Although habitability checks were routinely conducted in the

EOF, no habitability checks were observed in the control room, TSC, and the

Operations Support Center.

No violations or deviations were identified.

16. Exercise Critique (82301)

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The licensee's critique of the emergency exercise was observed to determine

that deficiencies identified as a result of the exercise and weaknesses

noted in the licensee's emergency response organization were formally

presented to licensee management for corrective actions as required by

10 CFR 50.47(b)(14),10 CFR 50, Appendix E, paragraph IV.E, and specific

criteria in NUREG-0654,Section II.N.

A formal licensee critique of the emergency exercise was held on

September 26, 1985, with exercise controllers, key exercise participants,

licensee management and NRC personnel attending. Many but not all of the

weaknesses in the emergency preparedness program, identified as a result of

this exercise were presented by the licensee. NRC also presented a summary

of exercise findings. Followup of corrective actions will be accomplished

through subsequent NRC inspections.

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1.17. Inspector Followup (92701)._

c . (Closed) The' previous unresolved item (50-348,364/84-26-01)- addres. sing the

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. failure of:the; licensee. to develop and' fully use required prcnot notifica -

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, tion Jcapability: for emergency action classification i s closed -and

. reclassified .as _a violation -(50-348/85-03-01,364/85-37-01).

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.-paragraph-9 of-this. report.

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